Opportunity to furnish unsecured-loan confirmations is required before reassessment initiation; proceedings require fresh consideration after taxpayer...
Under-reporting on a first reassessment return attracts penalty, while enhanced misreporting penalty requires proof of a statutory misreporting catego...
In transfer pricing comparability, Excel Infoways Ltd. was excluded because Tribunal precedent noted low employee cost and fluctuating margins, and that exclusion was upheld. Jindal Intellicom Ltd. was directed to be included in the final comparable set because it had been accepted in the assessee's own earlier year and no material change in functional profile was shown for the relevant year. The Tribunal also held that working capital adjustment must be allowed while giving effect to the order, as differences affecting comparability must be adjusted in the profit margin of independent comparables. Revenue's appeal was dismissed and the assessee's cross-objection was partly allowed.
In transfer pricing comparability, Excel Infoways Ltd. was excluded because Tribunal precedent noted low employee cost and fluctuating margins, and that exclusion was upheld. Jindal Intellicom Ltd. was directed to be included in the final comparable set because it had been accepted in the assessee's own earlier year and no material change in functional profile was shown for the relevant year. The Tribunal also held that working capital adjustment must be allowed while giving effect to the order, as differences affecting comparability must be adjusted in the profit margin of independent comparables. Revenue's appeal was dismissed and the assessee's cross-objection was partly allowed.
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TaxTMI 
TaxTMI 
of 4916 
